Procedure: Food Supplements MA
Country: Global Procedure
Version #: 01/09/2024
Author: Maria Ivanova
Editor: Vlad Reznikov
ID: GP-SUP-MA-SR
Category: Supplements
Validity: Defined by NRA, until renewal or change
Certified by: Vlad Reznikov
Copyright: Pattern of USA Inc.
SUMMARY
The global regulation of food supplements involves diverse requirements and market authorization processes, shaped by the distinct regulations of individual countries or regions. This encompasses diverse aspects, including ingredient and formulation standards, where different nations maintain specific lists of permitted and prohibited components, requiring compliance with established safety criteria. Good Manufacturing Practices (GMP) are often mandated to ensure product quality, safety, and consistency. Accurate labeling, supported by scientific evidence for health claims plays a crucial role, demanding clear and accurate information on ingredients, dosage, and usage instructions, with health claims necessitating scientific support and adherence to regulatory guidelines. Notification or approval procedures vary, with some countries mandating pre-market registration. Safety assessments, encompassing toxicity and risk analysis, are obligatory to ensure consumer well-being. Packaging and storage requirements are defined to maintain product integrity. Regulatory authorities, such as the FDA, EFSA, and TGA, oversee market authorization in respective countries. Post-market surveillance, including mandatory adverse event reporting, is common. International efforts aim for harmonization, exemplified by organizations like Codex Alimentarius, emphasizing the importance for manufacturers and distributors to comprehend and adhere to specific market regulations to ensure the legal and safe distribution of food supplements. Many products combine the characteristics of medical devices, medicinal products, food supplements, cosmetics and biocides to form the so-called borderline product group. Inappropriate qualification of a product may result in a decision by the supervisory authorities to suspend/withdraw it from the market.

Must-Have Requirements, Recognized Standards, and Certifications:
- Authorized Representative
- Manufacturer’s certificate of registration with GMP compliance when needed
- Valid Phytosanitary Certificate/ Health Certificate
- Free Sale Certificate issued by NRA or Chamber of Commerce in the country of origin
- Compliance with Labeling Requirements
- Notification to Rapid Alert System for Food and Feed (RASFF)
- Valid HACCP Certificate issued in the country of origin
- Valid ISO 22000 Certification preferred
- Certificate of Analysis (CoA)
Nice-to-have:
- Certificates to use of logo/seal on Halal, Organic, Kosher, Sangkap Pinoy, etc. if so
Typical Gaps and Deficiencies: Gaps in documents; official records of withdrawal of goods and/or imposition of fines
Implementation Period: Immediately
Deliverables: Compliance to local regulations; MA certificate or approval where require
PHASE | TASK | TASK | START | DURATION | Fee | KPI | ||
NUMBER | TITLE | OWNER | W/M/Q/Y | in weeks | 3rd Party | Service | State | |
0 | In-house Pre-Submission Activity | |||||||
0.1 | NDA signing or validation | Executor | week 1 | 1 | ||||
0.2 | Contract Closing | MAH | week 1 | 1 | ||||
0.3 | POA issuance and shipping | MAH | week 1 | 1 | ||||
0.4 | Invoice is sent to MAH and paid | Executor | week 1 | 1 | ||||
0.5 | Legal Document processing | Executor | week 2 | 1 | ||||
0.6 | Legal Document Translations, Notary, and Apostilles | 3rd party | week 2 | 2 | ||||
0.7 | SOW is approved by MAH | Executor | week 4 | 1 | SOW | |||
I | Submission | |||||||
I.1 | Providing documents and registration file | MAH | week 5 | 1 | ||||
I.2 | Document processing | Executor | week 6 | 2 | ||||
I.3 | Preparation of the dossier and samples | Executor | week 8 | 1 | ||||
I.4 | Dossier submission for registration | Executor | week 9 | 1 | Application | |||
I.5 | NRA payment | MAH | week 10 | 1 | Confirmation | |||
II | NRA Evaluation | |||||||
II.1 | Examination of the dossier | NRA | week 11 | 4 | ||||
II.2 | Sanitary and hygienic trials | NRA | week 15 | 2 | ||||
II.3 | Approval or Query | NRA | week 17 | 2 | Approval or Q&A | |||
III | Q&A | |||||||
III.1 | Analysis and addressing Qs to MAH | Executor | week 19 | 1 | ||||
III.2 | Answering with relevant documents | MAH | week 19 | 1 | ||||
III.3 | Official Response Evaluation | NRA | week 20 | 2 | ||||
III.4 | Approval or Query | NRA | week 22 | 1 | Approval or Q&A | |||
F | Final Phase In-house Post-Authorization Activity | |||||||
F.1 | Service Acceptance Certificate signing | MAH | week 23 | 1 | ||||
F.2 | Final Invoice | Executor | week 23 | 1 | ||||
F.3 | Final Payment | MAH | week 23 | 1 | ||||
F.4 | Contract Termination | Executor | week 23 | 1 | ||||
F.5 | Archiving and limiting access | Executor | week 24 | 1 | Archiving |
Feel free to submit a Request for Proposal (RFP) for a specific country or territory to info@patternofusa.com